`U.S. Patent No. 7,979,023
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
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`UNIFIED PATENTS INC.
`
`Petitioner
`
`v.
`
`CARUCEL INVESTMENTS, L.P.
`
`Patent Owner
`
`———————
`
`Case No. IPR2019-01079
`U.S. Patent 7,979,023
`
`———————
`
`DECLARATION OF CHARLES D. GAVRILOVICH, JR. IN SUPPORT OF
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`Carucel Investments—Exhibit 2001
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 1
`
`
`
`IPR2019-01079
`U.S. Patent No. 7,979,023
`
`I, Charles D. Gavrilovich, Jr., declare:
`1. I am over the age of twenty-one years and am competent to make this
`
`declaration. The facts stated herein are within my personal knowledge and are
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`true and correct. I am an attorney with Gavrilovich, Dodd & Lindsey, LLP in
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`Chula Vista, California and I represent the Patent Owner in this proceeding.
`
`2. Attached to this Declaration as Patent Owner’s Exhibit 2002 is a true and
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`correct copy of a screenshot of the home page for Unified Patents, Inc.
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`retrieved on August 17, 2019, available at https://www.unifiedpatents.com/
`
`3. Attached to this Declaration as Patent Owner’s Exhibit 2003 is a true and
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`correct copy of an article by Marta Belcher and John Casey entitled “Hacking
`
`the Patent System: A Guide to Alternative Patent Licensing for Innovators”.
`
`Juelsgaard Intellectual Property & Innovation Clinic, Stanford Law School
`
`(2014),
`
`as
`
`archived by
`
`the Wayback Machine, available at
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`https://web.archive.org/web/20140905000728/http://unifiedpatents.com/wp-
`
`content/uploads/2014/06/hacking_ the_patent_system.pdf.
`
`4. Attached to this Declaration as Patent Owner’s Exhibit 2004 is a true and
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`correct copy of screenshots of Unified Patents’ public webpage for the date
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`June 6, 2014, featuring the article “Hacking the Patent System: A Guide to
`
`Alternative Patent Licensing for Innovators” available for download, as
`
`Carucel Investments—Exhibit 2001
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 2
`
`
`
`IPR2019-01079
`U.S. Patent No. 7,979,023
`
`archived
`
`by
`
`the
`
`Wayback
`
`Machine,
`
`available
`
`at
`
`https://web.archive.org/web/20140606010956/http://unified patents.com/
`
`5. I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true andcorrect.
`
`_
`
`Executed this 21st day of August 2019. Charles D.Gavtilevich, Jr.
`
`Carucel Investments—Exhibit 2001
`,
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 3
`
`